A qualifying trade is one which is conducted on a commercial basis with a view to the realisation of profits and does not, at any time during Period B (see ¶323-030), consist wholly or substantially of one or more of the prescribed ‘excluded activities’ (ITA 2007, s. 189(1)).

The list of excluded activities comprises:

(1)dealing in land, in commodities or futures or in shares, securities or other financial instruments;

(2)dealing in goods otherwise than in the course of an ordinary trade of wholesale or retail distribution (see ¶323-420);

(3)banking, insurance, money-lending, debt-factoring, hire-purchase financing or other financial activities;

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